REACH is a very demanding system for any business either large or small, yet right from the start one of the more serious concerns was whether and how SMEs could cope with the Regulation. After all, some 27,600 companies in EU chemistry are SMEs (95% of all firms). Seven years down the line, many of these fears are materialising. Assuming no significant changes are introduced to REACH, this paper suggests the following recommendations:
- Above all, we strongly encourage SMEs to start early and develop a strategy for REACH compliance well before 2018.
- Address the potential competition law implications of current SIEF arrangements, e.g. through a Guidance document from DG Competition by 2014 (in time for 2018)
- Facilitate the exchange of information along the value chain by adopting pragmatic approach to the content and format of Safety Data Sheets. More can be done on the IT front as well, for instance by developing tools that generate compliant Safety Data Sheets.
- Improve the communication of REACH and its intended goals, that is, the health and environmental benefits, to the wider public. SMEs regret the unawareness of the public in the light of the enormous efforts they have to undertake.
- In the event of a later review of REACH, the logic should be risk-based rather than hazard-based.
Ineke Gubbels is Director of IGCON BV; Jacques Pelkmans is Senior Research Fellow, CEPS and Lorna Schrefler is Research Fellow and Head of the Regulatory Affairs unit, CEPS.